Request for a Certification to the Effect that PNB is Not Subject to the Expanded Withholding Tax (EWT) under Revenue Regulations No. 12-94

July 31, 1995 BIR RULING NO. 117-95 RR 6-85 000-00 117-95 Philippine National Bank Escolta, Manila Attention: Mr . Ma . Teodoro Josephat C . Martinez, Jr . Assistant Vice-President Gentlemen : This refers to your letter dated February 15, 1995 requesting for a certification to the effect that you are not subject to the expanded withholding tax (EWT) under Revenue Regulations No. 12-94. prll In reply, please be informed that pursuant to Section 3 of Revenue Regulations No. 12-94, amending Section 4 of Revenue Regulations No. 6-85, stating "Section 4. Exemption from Withholding . The withholding of tax prescribed in these regulations shall not apply to income payments in the following cases: "(a) Income payments to the national government and its instrumentalities, including provincial, city or municipal governments, as well as government-owned or controlled corporations; . . ." (Emphasis supplied) your opinion that as a government-owned or controlled corporation, you are not subject to the expanded withholding tax prescribed under Revenue Regulations No. 12-94, is hereby confirmed. This serves as your certification that income payments to you are not subject to the expanded withholding tax. cdtech Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue